Lindsay Lohan is putting on notice the Hookah manager who claims she hit him with her Porsche as she left a Hollywood nightclub that if he files a civil lawsuit against her the actress will counter-sue and will hold him responsible for the allegations he has made, RadarOnline.com is exclusively reporting.

As we previously reported Lohan, 25, was leaving Sayers Club in Hollywood shortly after midnight last Wednesday in her new black Porsche when she was blocked by a swarm of paparazzi and club patrons from the nearby Hookah Lounge.

As she attempted to navigate a three point turn to get out of the alley, she allegedly grazed the manager of the Hookah Lounge. Initially, a source close to the situation told RadarOnline.com, the manager told cops at the scene that he wasn’t hit by the car, but after finding out that Lohan was the driver, the manager went to a hospital emergency room, lawyered up and changed his story.

“Lindsay won’t be taken advantage of by this opportunist, which he clearly is. Lindsay has told her attorney, Shawn Holley, to convey to the Hookah manger’s lawyer that if he files a lawsuit against her Lindsay will come back at him with everything she has,” a source close to the situation tells RadarOnline.com. “Lindsay will immediately file a counter-suit against him, for libel, defamation and other claims. Lindsay is in the midst of a comeback right now and she won’t let this guy try and make a quick buck off of her. If he is smart he should recognize that he has no facts to support his allegations and take this no further.”

As RadarOnline.com previously reported, the Hookah manger’s credibility is already under scrutiny because he has changed his story several times. “Let’s be very clear, he has changed his story significantly. Officers on the scene specifically asked the man if the car had hit him and he was absolutely emphatic that it hadn’t, nor had he claimed it hit his car,” a law enforcement source told RadarOnline.com. “Several hours later, the man’s newly hired lawyer called the Hollywood division of the LAPD and said that his client wanted to provide a statement because he was the victim of a hit and run accident. The manager claimed that he was in shock after the accident and that his foot began hurting and went to the hospital. He now says there is no doubt that Lindsay drove over his foot and fled the scene.”

Meanwhile, Lindsay vehemently denies hitting the man, and declared on her Twitter account, “Scrape? This is all a complete lie. I’ve been at community service. Last night, I attempted to wish a friend happy birthday, which I didn’t even get to do because I was freaked out by all of the paparazzi. These false accusations are absurd.”

“Lindsay immediately notified her probation officer about the allegations the manager had made against her. She is doing everything required of her, she is so close to the end of her legal issues and she doesn’t want this to trigger a whole new round of legal problems,” the insider says.